Exchange of information: treaty requires information sharing regardless of residency but limited by territorial possession. Article 2 requires Contracting Parties to exchange tax information irrespective of the person's residency or where information is held, but a Requested Party is not obliged to provide information that is neither held by its authorities nor in the possession or control of persons within its territorial jurisdiction.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Exchange of information: treaty requires information sharing regardless of residency but limited by territorial possession.
Article 2 requires Contracting Parties to exchange tax information irrespective of the person's residency or where information is held, but a Requested Party is not obliged to provide information that is neither held by its authorities nor in the possession or control of persons within its territorial jurisdiction.
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